Introduction

Kingpin Security is committed to conducting all aspects of our business with integrity, transparency, and in compliance with all applicable laws and regulations. This Anti-Bribery and Corruption Policy reaffirms our stance against all forms of bribery and corruption, aligning with the UK Bribery Act 2010 and similar laws in other jurisdictions where we operate.

Policy Statement

We strictly prohibit the offering, giving, solicitation, or acceptance of any bribe, whether cash or other inducement, to or from any person or company, regardless of their location or status. This policy applies to all employees, contractors, consultants, agents, and anyone else acting on behalf of Kingpin Security.

Key Principles

• Zero Tolerance: Kingpin Security has a zero-tolerance approach to bribery and corruption. Acts of bribery are not only illegal but also contrary to our core values of honesty and integrity.
• No Facilitation Payments: We do not make, and will not accept, facilitation payments or "kickbacks" of any kind. These are payments made to secure or expedite a routine government action.
• Gifts and Hospitality: Gifts, entertainment, or hospitality must be modest, reasonable, and appropriate. They must not influence or appear to influence business decisions. All such activities must be transparent, documented, and approved according to our internal guidelines.
• Political and Charitable Contributions: Any political or charitable contributions must be free from any expectation of business advantage and must be transparent, recorded, and authorized in line with our policy.

Due Diligence

• Business Partners: We will conduct appropriate due diligence on all partners, agents, and third parties we engage with to ensure they share our commitment to anti-bribery and corruption.
• Risk Assessment: Regular risk assessments will be performed to identify potential areas of exposure to bribery and corruption within our operations and supply chain.

Training and Communication

• Employee Training: All employees will receive training on this policy, the risks of bribery and corruption, and how to recognize and address these issues.
• Policy Communication: This policy will be communicated to all employees, suppliers, and business partners. It will also be publicly available on our website.

Reporting and Whistleblowing

• Reporting Mechanism: Employees and others are encouraged to report any suspicion of bribery or corruption through our confidential whistleblowing channel without fear of retaliation.
• Investigation: All reports will be investigated thoroughly and promptly. Appropriate action will be taken, which may include disciplinary measures, up to and including dismissal, and legal action where necessary.

Monitoring and Review

• Compliance Monitoring: We will continually monitor compliance with this policy through audits and reviews.
• Policy Review: This policy will be reviewed annually or in response to significant legislative changes, to ensure it remains effective and relevant.

Consequences of Breach

Violation of this policy will result in disciplinary action, which may include dismissal, and could lead to criminal or civil penalties for those involved. Kingpin Security may also face legal consequences for failing to prevent bribery.

This Anti-Bribery and Corruption Policy is endorsed by the Board of Directors of Kingpin Security and is effective from 15/12/2024

Contact Information

For questions regarding this policy or to report any concerns, please contact our Compliance Officer at [email protected]